ACP: Governmental Affairs and Public Policy - ACP Offers Support and Assistance to the Department of Health and Human Services in Improving Interoperability of Health Information Technology

Advocacy

ACP Offers Support and Assistance to the Department of Health and Human Services in Improving Interoperability of Health Information Technology

July 5, 2005

Michael O. Leavitt
Secretary of Health and Human Services
U.S. Department of Health and Human Services

Washington, DC 20515

Via Fax: (202) 228-1264

Dear Secretary Leavitt:

The American Academy of Family Physicians, American Academy of Pediatrics, American College of Obstetricians and Gynecologists, and the American College of Physicians are writing to offer our support and assistance in developing a process to improve the interoperability of health information technology (HIT) and computer systems that collect, manage, and transmit patient data, and, specifically, to improve the manner in which HIT standards are developed, maintained, and harmonized to effect interoperability. Collectively, we represent over 300,000 physicians and medical students in the U.S.

We believe that the medical profession has a professional and ethical responsibility to engage in activities to continuously improve the management of patient health information, and to help assure the accuracy, accessibility, timeliness, and relevance of the information used in the making of clinical decisions. The Institute of Medicine’s landmark report, Crossing the Quality Chasm, documented significant gaps in health care quality and issued a challenge to the profession to work collaboratively to improve quality, safety and access. We all recognize the significant potential of the appropriate implementation and use of HIT to contribute to these needed improvements. Our organizations accept this challenge and believe that the Department of Health and Human Services can play an important role in creating the mechanisms to assure that electronic health records (EHRs) and other HIT products and services used by physicians and other clinicians in medical practices, hospitals, and many other care settings, have the capability to interoperate and exchange the most relevant health summary information, and to do so at low cost using appropriate industry (both health care and outside health care) standards.

Specifically, and in relation to the recent announcement by HHS of the RFP entitled “Evaluation of Standards Harmonization Process for Health Information Technology,” of June, 6, 2005, we want to support the effort to develop, reconcile, set, and maintain standards required to achieve this level of interoperability. We think it very important that such a process have the following characteristics and features:

Bidders on this RFP contract should state explicitly how they will involve the medical specialty societies, how the physician membership organizations will be given the opportunity to participate, and in what areas it is expected that the physician membership organizations will take the lead in setting priorities and defining key issues. Physician staff and member representatives of the AAFP, ACP, AAP, and ACOG have been engaged in recent national standards development with respect to EHRs and HIT interfacing with laboratory systems, pharmacies, PBMs, other EHRs, hospital systems, as well as connectivity with several other key target areas where there is a fundamentally strong business case for interoperability. We would hope that HHS would take into consideration in awarding this contract the accumulated experience and knowledge that has been gained by the medical specialty organizations with respect to interfaces, connectivity, and interoperability.
This RFP gives a central role to the development of specific use-cases (Task 3), “which are illustrations of the applicability and business need for all areas of standard for interoperability.” While we strongly agree with this practical and proven approach, we want to assure that the limited number of use-cases anticipated (three per year) reflect the needs and aspirations of practicing physicians who are in the market for EHRs and other HIT products and services for their practices. Physician experts in information technology and standards representing the medical specialty societies must play a key role in determining the use-cases that are the subject of and key provision of this proposed contract, because office-based physicians and medical practices are the major locus of the impact that the standards related to interoperability will have on cost, quality, safety, workflow and efficiency in the US health care system. Implementation of the recommendations ensuing from the fulfillment of this contract could lead to improvements at the practice level for all of these parameters, and, conversely, it could portend greater expense and complexity with which the practices would have to grapple.
There should be complete transparency surrounding the process and all phases of the contract, including the work plan, prioritization of activities, the choices for use-cases, and the testing and evaluation of standards chosen to meet the objectives of interoperability afforded by the use-cases. It is critically important that all stakeholders of this process, particularly physicians in medical practices, have the opportunity to monitor, review, and comment upon the many sub-processes involved in the contract, in part because of the cross-over and synergies that will exist between this effort and several other related activities (including other HHS RFPs) that have the potential to directly affect the cost and quality of HIT products and services that are offered in the marketplace to physicians in small and medium size medical practices. It seems to us that the opportunity for “mixed signals” could be high. And we would hope that transparency and open communications would minimize both the possibility that physicians might choose to delay purchasing EHRs and other HIT products and services until the contract is completed, as well as the possibility that significant replacement costs will be incurred because of unexpected and unanticipated announcements emerging with respect to standards.

We recognize the challenges in creating a standards harmonization and reconciliation process for Medicare and the other health programs and departments within the federal government. We have concerns that the realities and requirements faced by our physician members, most of whom practice in small and medium sized independent community-based practices, which is where the majority of health care delivery occurs, may not be the same as or may not be addressed by the bidders to this RFP and the winner of the contract. However, we believe that these concerns and challenges can be overcome if the medical profession engages constructively with the federal government by providing our expertise and perspectives. We offer you our commitment to achieving this goal.

Sincerely,

American Academy of Family Physicians
American Academy of Pediatrics
American College of Obstetricians and Gynecologists
American College of Physicians

Cc: David Brailer, MD, PhD